Privacy Policy

The website “www.kea360villas.gr” (hereinafter referred to as the “Website”), belongs to the legal entity under corporate name ESTATE DEVELOPMENT, with its registered office located at 14 Agiou Dimitriou str., Petroupoli, 13231, Greece, under tax number 801238755 (hereinafter referred to as the “Company”).

This Privacy Statement describes the personal information which we collect, how the personal data is collected, the purpose for collection and processing personal data and your rights according to data protection legislation.

Ensuring the security of your personal data and safeguarding your privacy is our top priority. As the administrators of this website, we aim to provide you with transparent information about the collection and usage of your personal data, as well as its implications when you utilize our services.

Please review the following details attentively. It’s your responsibility to ensure that others you represent, such as those listed with you on a booking, are familiar with the contents of this Privacy Policy. Please confirm with them that they consent to their personal data being shared with us for the purpose of making a booking or any other purchase on their behalf.

When you make a booking or any other purchase, or when you provide us with your personal data in any other way, we will handle, store, and process it as outlined below. We are committed to taking all necessary measures to ensure that your data is treated securely and in compliance with this Privacy Policy. We will implement appropriate security measures to safeguard your personal data from accidental loss and unauthorized access, use, alteration, and disclosure.

Please note that our website may include links to the websites of other providers, which are not governed by our privacy policy. We do not have control over whether these operators adhere to data protection regulations.

What types of personal data we collect

Personal data is any information relating to natural persons whose identity is or may be identified directly or indirectly, or characteristics identifying the physical, genetic, psychological, economic, cultural or social identity of that natural person.

The Company collects Personal Data in accordance with legal provisions such as name, surname, identity no or passport no, tax registration number, home or work address, telephone number, e-mail address, date and place of birth, nationality, gender, credit and debit card number or other payment data, travel itinerary, tour group or activity data, prior guest stays or interactions, goods and services purchased, special service and amenity requests, social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts, data about family members, guest preferences, inquiries and comments and any other personalized data, such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your stay.

We will gather and utilize your personal data only if one or more of the following conditions are met:

You have given us your consent.
It is essential for establishing a contract with you or for carrying out actions at your request before entering into a contract.
It is obligatory for us to comply with legal requirements.
It is imperative to safeguard your vital interests or those of another individual.
It serves a public interest, or we have official authorization to do so.
It aligns with our legitimate interests or those of a third party, and such interests are not outweighed by your rights or interests.

Sensitive personal data is personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data for the undeniable identification of a person, health-related data. We do not collect sensitive personal data, unless specifically requested for certain purposes, such as for the purpose of your treatment at the spa facilities and in order to comply with our various legal obligations.

Processing of personal data is any act or series of act carried out with or without the use of automated means in personal data or in sets of personal data, such as collection, registration, organization, structure, storage, adaptation or alteration, retrieval, information search, use, disclosure, spreading, otherwise making available, the association or combination, restriction, deletion or destruction of personal data, whether in electronic form (electronic file) or in printed form (physical file).

Personal data you give to us

When you initiate a booking, purchase, or inquiry, whether through email, post, phone, or via social media channels, we may request your personal information such as your name, address, email, and phone number. This data collection is necessary to facilitate the services you are seeking. Additionally, we may gather information regarding digital communications, including emails, and any interactions with links therein that you engage with.

In the process of arranging a booking as per your specifications, we may inquire about any special requirements you may have, potentially leading to the disclosure of sensitive personal data. This information aids us in tailoring our services to meet your specific needs. Should you choose not to furnish us with this data or request its cessation, it might impact our ability to fulfill all or parts of the services you’ve requested. In such cases where we must cancel your booking or purchase due to lack of necessary information, you may be subject to a cancellation fee.

If you participate in a competition, promotion, survey, or if you report any issues with our services, we will collect your name, relevant contact details, and any additional personal data you provide us.

We may request to view and retain copies of passport details and other forms of identification, particularly if you are checking in at a villa.

When you contact us through online channels, we may maintain a record of your email or other forms of correspondence. Similarly, if you communicate with us via telephone, we may monitor and/or record phone conversations for training and customer service improvement purposes.

To assist us in maintaining the accuracy, completeness, and currency of your information, kindly inform us promptly of any necessary changes.

How we collect Personal Data

The Company collects Personal Data when you make a reservation, purchase services from our website, communicate with us or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, questionnaire, contest or promotional offer. Furthermore, we collect Personal Data when you visit our villas premises, complete certain forms (i.e. Guest Registration and Information Form) or use services such as restaurants, concierge services, child care services and spa treatments. We may also collect Personal Data when you attend an event that we host or you organize an event at our premises. Finally, the Company collects Personal Data from other sources such as travel agents and authorized licensor.

Purpose for collecting Personal Data

The Company asks you to provide us with personal information for the purposes of assisting us in improving the villas administration and management, particularly our reservations procedures and guest services and in order to comply with our various legal obligations. We use Personal Data to provide services you request, including to facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit, to complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service. In addition we use Personal Data to personalize the services rendered to you, according to your preferences and personal needs. Furthermore with your consent we use your personal data for direct marketing or market research and in order to notify you of new services and offers, to offer and manage your participation in our global loyalty programs and with your consent to communicate your personal data to third party business partners for direct marketing.

How we use Personal Data

To deliver our services to you effectively, we utilize the information we possess in various ways. We process your information either because it’s essential for fulfilling a contract you’ve entered into, or because we have legitimate business interests for doing so.

The following activities are conducted by us using your personal data because they are necessary for a contract you’ve entered into, or because you’ve requested them to facilitate entering into a contract:

Administering your booking internally and communicating your booking externally with our suppliers to ensure the requested services are arranged.
Communicating with you regarding your booking or any other purchase, including sending booking confirmations and relevant documents.

We may utilize and process your personal data as outlined below when it is necessary for us to conduct activities that align with our legitimate interests as a business:

To improve customer experience:

Enabling you to engage in interactive features of our website, should you choose to do so.
Ensuring that content from our website and booking systems is presented in the most effective manner for you and your device.
Notifying you about any changes to our service.

To protect our business against financial loss.
For debt collection or credit vetting.
For payment card and booking verification.
To maintain a safe and secure environment and prevent and detect criminal activity.
Using CCTV in our premises.
To promote our business, improve our products, services, and day-to-day operations, including:

Sending marketing correspondence about products and services similar to those you have previously purchased from us. You can opt out of receiving electronic marketing information, and this option will be included in every marketing message.
Contacting you if you’ve made an inquiry on our website but have not completed a booking, to address any issues or provide assistance.
Conducting internal research/analysis to enhance the quality of our services and products, as well as develop new products. This may involve inviting customers to participate in surveys or discussion groups, or analyzing aggregated customer data to make informed decisions.

Promoting our business, brands, and products and measuring the reach and effectiveness of our campaigns, including:

Contacting you with targeted advertising delivered online through platforms like Google DoubleClick and social media, based on information about you that we have provided to the platform or because the platform has identified you as having similar attributes to others.
Sharing your personal data with technology companies or platforms to obtain more information about you and match their records with ours, potentially using cookies for this purpose.

To support any potential company sale or acquisition in the event of a sale or purchase of any business or assets, we may disclose your personal data to prospective sellers or buyers.

We utilize this information in two primary ways:

Identifying links between your attributes and behaviors to market to others with similar attributes in our direct marketing campaigns and through targeted advertising on our website or third-party platforms, including social media channels.
Tailoring and personalizing our interactions with you to make them more relevant to your interests, including your website journey, the content displayed, and marketing communications sent to you. Please refer to ‘How do we personalize our marketing to you?’ for more details.

We may utilize and process your personal data in the following ways:

In your vital interests: We may assist you or arrange for assistance to be provided by third parties, particularly in the event of an incident or emergency, where we deem it necessary for your well-being.
With your consent: We may use and process your personal data when we have obtained your explicit consent:
To assist you or arrange assistance by third parties if you have special requirements related to sensitive personal data.
To send marketing correspondence about our products and services, provided you have granted permission. Please refer to the section ‘When and how do we use your information for marketing?’ for more details.
In compliance with legal requirements: We and third parties acting on our behalf, such as external law firms, may use and process your personal data under the following circumstances:

Resolving complaints, managing disputes, and handling legal proceedings, which may involve proactive communication with you to address any issues related to bookings or purchases.
Responding to requests from government bodies, law enforcement agencies, courts, or regulatory authorities, in accordance with applicable data protection laws.
For anti-money laundering and terrorist financing purposes.

Processing subject to national laws: Additionally, we may use and process your personal data, including special category data such as health information for insurance purposes, when we have a specific legal basis to do so under applicable data protection law.

Transfer of Data

The Personal Data is stored to our central computer database/ local database. The Company may also disclose Personal Data to the extent required by the rules of any law, court order or any governmental or regulatory authority.

To ensure the confidentiality of all information you provide, we have various security measures in place such as limited and computer passwords and we seek to use organizational and technical measures to protect Personal Data.

Personal data of children

The Company does not request from individuals under the age of eighteen to provide with Personal Data. Our website and services are not intended for children, and therefore, we do not knowingly gather information, including personal data, from individuals who are not legally permitted to use our platform and services. In cases where there is a lawful basis for processing (which may involve consent from the minor’s guardian or for contractual fulfillment purposes), we may collect information from minors. If we become aware that we have inadvertently collected personal data from a child under the legal age of consent without a lawful basis, we will promptly delete such information unless legally obligated to retain it. If you suspect that we have mistakenly collected information from a child under the legal age of consent, please contact us.

How you can request to have access, change, delete or withdraw your consent

You are welcome to see the information held about you at any time, to request us to make any necessary amendments to keep it up to date, rectifications of inaccurate personal data, erasure or restriction of processing of personal data, or if you would like to receive an electronic copy of your Personal Data. You may also withdraw your consent at any time. Please send your relevant request to the email address [email protected]

Retention

We will retain your Personal Data for a specific period of time in order to fulfill the purposes as described in this Privacy Statement, unless a longer retention period is required by law.

Where is your data stored

Your personal data is stored within a combination of our proprietary systems and the systems of the suppliers we engage to deliver our services.

When you provide us with your personal data, certain information may need to be shared with and processed by relevant third parties. These third parties encompass:

Our technology and data management partners, who assist us in administering the services we offer (such as Busy Rooms Group, who provide central reservation services).
Our contact center partners (including those facilitating live chat forums), who provide services to support customer inquiries.
An organization to which we sell or transfer (or engage in negotiations to sell or transfer) any of our businesses or any rights or obligations under any agreement we have with you. If such a transfer or sale occurs, the receiving organization may utilize your personal data in the same manner as us.

We may be required to disclose personal data to assert, exercise, or defend our legal rights, which may involve sharing personal data with others to prevent fraud and mitigate credit risk. Identity verification checks may be conducted to confirm your identity, aiding in safeguarding against identity theft, fraud, and the prevention and detection of crime or money laundering. In this case, we may share the minimum personal data necessary with other public authorities if the law says we must, or we are legally allowed to do so

Your rights in relation to your personal data we hold about you

You have a number of rights in relation to your personal data under data protection law, including:

Your Right to Access Your Personal Information
Your Right to Rectification
Your Right of Erasure
Your Right to Restriction of processing
Your Right to Object to processing
Your Right to Data portability

How to contact us

You have a right to ask for a copy of the personal data we hold about you, although you should be able to access online the personal data associated with your account or booking.

You can contact us if you have a complaint about how we collect, store or use your personal data. We aim to resolve complaints but if you are dissatisfied with our response, you may complain to the Information Commissioner’s Office. To contact us about this Privacy Policy, to make a Data Subject Access Request, or a data protection related complaint, please submit your complaint or request. Any subject access request can be made in writing to:

ESTATE DEVELOPMENT, 14 Agiou Dimitriou str., Petroupoli, 13231, Greece

or email to: [email protected]

Once you have made your request and provided us with the information, we need to begin a search for the data we hold on you (including proof of identity), we will have 30 days to respond.

Updates to the Privacy Statement

The Company may revise this Privacy Statement in order to comply with its various legal obligations. Any changes will become effective when we post the revised Privacy Statement to our website.